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Guaranty Trust Co v. York

Guaranty Trust Co v. York. Issue? State S/L in diversity cases Decision State S/L applies Does the RDA apply to this case? Why or why not? What does that tell us about the basis for the Erie doctrine?. Discussion Hypo Under Guaranty. Burden of Proof Bifurcated Trial.

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Guaranty Trust Co v. York

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  1. Guaranty Trust Co v. York • Issue? • State S/L in diversity cases • Decision • State S/L applies • Does the RDA apply to this case? • Why or why not? • What does that tell us about the basis for the Erie doctrine?

  2. Discussion Hypo Under Guaranty

  3. Burden of Proof Bifurcated Trial

  4. Guaranty Trust Co v. York • What test or approach does the court apply? • Outcome Determinative: • Diversity jurisdiction should not • Substantially affect outcome • Significantly affect result • So far as legal rules determine the outcome • Clone: • Federal Courts in diversity cases are effectively only another court of the state.

  5. Guaranty Trust Approach Significant Effect on Outcome? Yes No Apply Federal Apply State

  6. Two Quick Cases

  7. Cohen v. Beneficial Industrial • Issue? • State bond requirement in derivative actions • Decision • Apply state bond requirement • Note: D argued that FRCivP governed and said nothing about requiring bond

  8. Ragan v. Merchants Transfer FRCivP 3 Says Action Commenced State Law Says S/L Tolled Suit Filed Event + 2 Yrs Event Service Which Governs? What theory? Does this mean Erie trumps FRCivP?

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